There needs to be a framework standard for a consistent labelling and traceability system for construction products, according to a new government-commissioned report.
The 174-page Independent Review of the Construction Product Testing Regime sets out a 20-strong series of detailed recommendations. Former government construction adviser Paul Morrell OBE and energy and construction lawyer Anneliese Day KC wrote the review. It is published by the Department for Levelling Up, Housing & Communities.
The review looks across “the whole system of construction product regulation to provide an understanding of what needs to change before products are placed on the market – and, crucially, before they are placed in buildings”.
Morrell’s and Day’s sixteenth recommendation calls for the government and industry to develop a framework standard for a consistent labelling and traceability system for products, within which methods appropriate to the nature of each product can be developed and incorporated in product standards.
The framework standard would need to cover:
- provision of a unique product identification reference, derived from a sufficiently robust registration system to ensure traceability and (given that products in use may have a life that is longer than the product range or even the manufacturer) longevity – for example by use of the Global Trade Item Number system;
- the characteristics of a robust registration system;
- consistent terminology and protocols for the exchange of data;
- the information to be included – whether directly on the label and/or by a link (by use of a barcode or QR code, or possibly by RFID) to product information that is accessible elsewhere; and
- how labelling is to be attached to, or accompany, products of different types to ensure the prescribed information reaches end users.
Focus on the golden thread
Specifically focusing on the golden thread, the authors call on the government and industry to:
- set digital standards that conform to standards to be adopted for wider use in the digitalisation of the industry;
- establish protocols by which product information can be introduced into the golden thread and filtered so that it meets the needs of successive duty-holders without overwhelming them with extraneous material which obscures the essential information;
- make provision within those protocols for the transfer and protection of information necessary for retrospective traceability;
- consider those protocols in the context of wider information needs through the supply chain and the product/building life cycle, so that the gathering of information required for the golden thread can begin at any time from the product being made available on the market.
Finally, Morrell and Day also recommend that the government should develop statutory mechanisms to manage product substitution and make clear where responsibility for all the implications of substitution falls.
Among other recommendations, the authors also suggest the use of AI/computer modelling as alternatives or supplements to physical testing of construction products.
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